TEXAS ETHICS COMMISSION

Advisory Opinion Requests

Whether, under Section 572.070 of the Government Code, a state employee is required to report certain contacts with an employee of a university owned or controlled by the People's Republic of China? What are the reporting requirements for frequent contacts? (AOR-747.)

The Texas Ethics Commission is authorized by section 571.091 of the Government Code to issue advisory opinions in regard to the following statutes: (1) Chapter 572, Government Code; (2) Chapter 302, Government Code; (3) Chapter 303, Government Code; (4) Chapter 305, Government Code; (5) Chapter 2004, Government Code; (6) Title 15, Election Code; (7) Chapter 159, Local Government Code; (8) Chapter 36, Penal Code; (9) Chapter 39, Penal Code; (10) Section 2152.064, Government Code; and (11) Section 2155.003, Government Code.

Questions on particular submissions should be addressed to the Texas Ethics Commission, P.O. Box 12070, Capitol Station, Austin, Texas 78711-2070, (512) 463-5800 or opinions@ethics.state.tx.us.

Issued in Austin, Texas, on April 29, 2026.

TRD-202601696

Amanda Arriaga

General Counsel

Texas Ethics Commission

Filed: April 20, 2026

Regarding the application of the revolving door provision of Section 572.054(b) of the Texas Government Code to a former employee of Texas Department of Transportation ("TXDOT"). (AOR-748.)

Questions on particular submissions should be addressed to the Texas Ethics Commission, P.O. Box 12070, Capitol Station, Austin, Texas 78711-2070, (512) 463-5800 or opinions@ethics.state.tx.us.

Issued in Austin, Texas, on April 29, 2026.

TRD-202601697

Amanda Arriaga

General Counsel

Texas Ethics Commission

Filed: April 20, 2026

Does paying a social media company's users for engaging with political advertising content (viewing advertisements, watching videos, completing surveys, etc.) constitute bribery of a voter under Section 36.02(a)(1) of the Penal Code?

Does paying a social media company's users to complete a survey that includes questions about the user's voting intentions - where compensation is identical regardless of the user's answers - constitute prohibited vote-buying under Texas law?

What disclaimer and disclosure requirements under Chapter 255 of the Election Code apply to political advertisements posted on social media?

May candidates, political parties, and political committees use the requestor's social media platform to deliver political advertisements and compensate users for engagement with the advertisements without violating Texas election laws? (AOR-749.)

Questions on particular submissions should be addressed to the Texas Ethics Commission, P.O. Box 12070, Capitol Station, Austin, Texas 78711-2070, (512) 463-5800 or opinions@ethics.state.tx.us.

Issued in Austin, Texas, on April 29, 2026.

TRD-202601698

Amanda Arriaga

General Counsel

Texas Ethics Commission

Filed: April 20, 2026

Whether public resources were unlawfully used for a candidate's campaign video. (AOR-750.)

Questions on particular submissions should be addressed to the Texas Ethics Commission, P.O. Box 12070, Capitol Station, Austin, Texas 78711-2070, (512) 463-5800 or opinions@ethics.state.tx.us.

Issued in Austin, Texas, on April 29, 2026.

TRD-202601699

Amanda Arriaga

General Counsel

Texas Ethics Commission

Filed: April 20, 2026